The amending protocol to the 1988 income tax treaty between Brazil and India was signed on 24 August 2022. The protocol is the second to amend the treaty and includes the following main changes:
- The preamble is replaced in line with OECD BEPS standards;
- Article 2 (Taxes Covered) is replaced with updated provisions, including that the treaty covers Brazilian federal income tax and Indian income tax including any surcharge thereon;
- Article 4 (Resident) is replaced with updated provisions, incl…